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HomeMy WebLinkAbout09-5368 Burton Neil & Associates, P.C. By: Derek C. Blacker, Esquire ID. NO. 202150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff PORTFOLIO RECOVERY ASSOCIATES, LLC Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA MICHAEL D CRAIG : NO. OR- 5B&9 Clvt ( -Fr A 237 West King Street, Shippensburg PA 17257 Defendant CIVIL ACTION -LAW Complaint - Notice You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claim set forth against you. You are warned that if you fail to do so, the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERENCE AND INFORMATION SERVICE Cumberland County Bar Assoc. 32 South Bedford Street Carlisle, PA 17013 Telephone No. 717-249-3166 or 800-990-9108 125491 Burton Neil & Associates, P.C. By: Derek C. Blasker, Esquire ID. NO. 202150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 Attorney for Plaintiff PORTFOLIO RECOVERY ASSOCIATES, LLC IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 0 7' -r3 G 9?',rv%I 4-.c<o. MICHAEL D CRAIG 237 West King Street, Shippensburg PA 17257 Defendant CIVIL ACTION - LAW Complaint 1. The plaintiff is PORTFOLIO RECOVERY ASSOCIATES, LLC, with place of business located at 140 Corporate Boulevard, Norfolk, VA. 2. The defendant is Michael D Craig, who resides at 237 West King Street, Shippensburg, Cumberland County, Pennsylvania. 3. A Bank of America credit card was issued to the defendant with account number ending in 5183 hereinafter referred to as the credit card account. 4. Defendant accepted the credit card by making purchases, balance transfers and/or cash advances. 5. Monthly statements were sent to defendant each month which detailed the charges and credits made to the credit card account for the prior month. 6. The balance due on the credit card account is $18,445.74. 7. Defendant did not pay the balance due on the credit card account in full upon receipt of the monthly billing statements and also did not make the required minimum monthly payment set forth in the monthly billing statement. As such, defendant is in default on the credit card account. 8. Plaintiff purchased defendant's account and is now the holder and owner of the account. 9. Although demand was made by plaintiff upon defendant to pay the sum of $18,445.74, defendant failed and refused to pay all or any part thereof. Wherefore, plaintiff demands judgment against defendant in the sum of $18,445.74 and the costs of this action. P.C. By: Mere".1%asker, Esquire Attorney for Plaintiff The law firm of Burton Neil & Associates, P.C. is a debt collector. Verification 1 U1111 .?U,?fi{? is t SWkr"SA7' (Name of authorized representative) (*e or Position) for, PORTFOLIO RECOVERY ASSOCIATES, LLC, the within Plaintiff in this action, and that the statements of fact made in the foregoing Complaint are true and correct to the best of the undersigned verifier's knowledge and belief. The undersigned understands that the statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Date: 1310 q ,..- /?Z.-, ---d Name 125491 Michael D Craig Account number ending in 5183 299 F1L -` ?r?C`,G OF 'PHE - ? M1.G? 2009 SUL 33 1 H 3: 23 $'18.50 pp AIW ct? 5agoa e* aas rloa Sheriffs Office of Cumberland County R Thomas Kline Sheri Ronny R Anderson a??at of 4 uu?6rrf?? Chief Deputy rtG. A ? Jody S Smith Civil Process Sergeant OFF,CE OF -he S-ERIFF Edward L Schorpp Solicitor FILED-0j t CE BE PROMPOWNARY 28 99 AUG 19 AM 9. 13 CUM ? ;, ,?s +'uUNN PEN Vkg Portfolio Recovery Associates, LLC vs. Michael D. Craig Case Number 2009-5368 SHERIFF'S RETURN OF SERVICE 08/13/2009 12:40 PM - Tim Black, Deputy Sheriff, who being duly sworn according to law, states that on August 13, 2009 at 1240 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Michael D. Craig, by making known unto himself personally, defendant at 237 West Kinc Street, Apt. 1 Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time V handing to him personally the said true and correct copy of the same. SHERIFF COST: $46.00 August 14, 2009 SO ANSW S R THOMAS KLINE, SHERIFF By Depu Shieriff PORTFOLIO RECOVERY ASSOCIATES,LLC: 140 Corporate Boulevard, Norfolk, VA Plaintiff V. MICHAEL D CRAIG 237 West King Street Shippensburg PA 17257 Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-5368 CIVIL TERM : CIVIL ACTION - LAW Praecipe for Default Judgment Please enter judgment by default for want of an answer in the above case in favor of the plaintiff and against the defendant, and assess damages as follows: Principal: TOTAL $18,445.74 $18,445.74 Understanding that false statements herein made are subject to penalty under 18 Pa. C.S. § 4904 relating to unswom falsification to authorities, I verify that: 1. The above are the precise last-known addresses of the judgment debtor and creditor. 2. The annexed notice of intention to file this praecipe was mailed to all parties against whom judgment is to be entered and to their record attorneys, if any, after the default occurred, and at least ten days prior to the date of the filing of this praecipe. 3. Pursuant to Section 201(b)(1)(A) of the Servicemembers Civil Relief Act of 2003 (SCRA), the defendant is not in the military service of the United States based on information received from the defendant and/or the Department of Defense website. JUDGMENT BY DEFAULT ENTERED AND DAMAGES ASSESSED AS ABOVE. NOTICE GIVEN UNDER A. IV.P. 236 r Prothonotary _L::Z;;? Bu!tkC. Associates, P.C. By: Blasker, Esquire Attorney for Plaintiff I.D. NO. 202150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 The law firm of Burton Neil & Associates is a debt collector. 125491 PORTFOLIO RECOVERY ASSOCIATES, IN TIIE COURT OF COMMON PLEAS LLC Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 09-5368 CIVIL TERM MICHAEL D CRAIG Defendant : CIVIL ACTION - LAW Notice of Intention to File Praecipe for Default Judgment TO: Michael D Craig 237 West King Street Shippensburg PA 17257 IMPORTANT NOTICE 125491 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help. This office can provide you with information about hiring a lawyer. If you cannot afford to hire a lawyer, this office may be able to provide you with information about agencies that may offer legal services to eligible persons at a reduced fee or no fee. LAWYER REFERENCE AND INFORMATION SERVICE Cumberland County Bar Assoc. 32 South Bedford Street Carlisle, PA 17013 Telephone No. 717-249-3166 or 800-990-9108 DATE OF NOTICE: September 15, 2009 In making this communication, we advise our office is a debt collector. Burton By: Derek C.13rask?, squire Attorney for Plaintiff Identification No. 202150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 (610) 696-2120 OF 4MITZiNTARf 2009 OCT - I PM 2= 18 CUM ??? i (-i NTY PENNSYLVANIA /'el'- ©o "d,4 4V44.4 4-1 S3 ?? --I a313ao y?a? s Burton Neil & Associates, P.C. By: Derek C. Blasker, Esquire ID. NO. 202150 1060 Andrew Drive, Suite 170 West Chester, PA 19380 610-696-2120 Attorney for Plaintiff PORTFOLIO RECOVERY ASSOCIATES, Plaintiff V. MICHAEL D CRAIG Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-5368 CIVIL TERM : CIVIL ACTION -LAW Rule of Civil Procedure NO. 236 (Revised) Notice is given that a JUDGMENT in the above captioned matter has been entered against you on Q6_4? 1, _-2 9 ?) " Prothono By: Deputy If you have any questions concerning the above, please contact: Derek C. Blasker, Esquire Attorney for Party Filing 1060 Andrew Drive, Suite 170 West Chester, PA 19380 Phone: 610-696-2120 The law firm of Burton Neil & Associates is a debt collector.